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CHF denominated transactions
The base rates for loans denominated in CHF (see circular letter) have all decreased compared to last year. Notably, the interest rates for equity-financed loans to related parties decreased from 1% (in 2025) to 0.75% (in 2026). Real estate loans from related parties for both housing and agriculture and for industry an commerce remained at 2% and 2.5% respectively. Operating loans up to CHF 1 million remain at 3.5% in 2026 for operating activities the rate remains at 3% in 2026 for holding activities. Meanwhile, the interest rates for operating loans exceeding CHF 1 million decreased from 1.75% in 2025 to 1.5% in 2026 for operating activities and from 1.5% in 2025 to 1.25% in 2026 for holding activities.
Non-CHF denominated transactions
Due to the current interest rate environment, the base rates for non-CHF denominated loans (see circular letter) have changed in some cases. In particular, the GBP safe harbour interest rate has been decreased from 4.5% in 2025 to 4% in 2026. The base rate for USD denominated loans has also been decreased from 4.25% in 2025 to 4% in 2026. Compared to last year, the rates for GBP and USD denominated loans thus allow for a slightly lower interest rate on intra-group loans. The base rate for EUR denominated loans remain unchanged at 2.5%.
The possibility to add an interest spread to the maximum interest rate for non-CHF denominated loans payable of a Swiss entity is maintained. For loan amounts up to the equivalent of CHF 1 million, a spread of 2.75% (operating activities) or 2.25% (holding activities) can be added; for loan amounts above the equivalent of CHF 1 million, a spread of 0.75% (operating activities) or 0.5% (holding activities) can be added. For example, for large USD denominated loans payable the maximum interest rate would be approx. 4.75% (USD base rate of 4% plus a spread of 0.75%).
For non-CHF denominated debt financed loans receivable, the interest spread (taxable margin) is still 50 bps (i.e., interest spread between related party loans receivable and payable).
A deviation from these interest rates remains possible by means of a third-party comparison, i.e., if the interest rates are at arm’s length. However, if such a comparison cannot be sufficiently evidenced, recent case law from the Swiss Federal Supreme Court (ruling no. 9C_690/2022 dated 17 July 2024) indicates that cantonal tax authorities are no longer bound by the safe harbour interest rates, but may themselves determine an arm’s length interest rate as part of the Swiss corporate income tax assessment. It remains unclear whether the SFTA will adopt a similar approach for Swiss withholding tax purposes.
Note that the application of unilateral safe harbour rates may fall under hallmark E.1. of the DAC 6 mandatory disclosure rules of the EU. Swiss companies applying the Swiss safe harbour interest rates on transactions with group companies domiciled in an EU member state should therefore be aware that these transactions might be reportable under DAC 6.
You can check the 2026 Swiss safe harbour interest rates for Swiss Franc (CHF) denominated transactions and for non-CHF denominated transactions in the PDF version below.
